Mercury

ECAR Fact Sheet for Wisconsin
Mercury

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The following fact sheet was prepared by the ECAR Center staff. Once prepared, each ECAR Center fact sheet undergoes a review process with the applicable state environmental agency(ies). You can check on the status of the review process here. Please read the disclaimer on the status page. While we have tried to present a summary of the essential information on this topic, you should be aware that other items, such as local regulations, may apply to you.

What You Need to Know

National Mercury Switch Removal Program

In late 2006, the Automotive Recyclers Association (ARA) became a partner in the National Vehicle Mercury Switch Recovery Program (NVMSRP) which is designed to remove mercury convenience light switches from scrap vehicles before the vehicles are flattened, shredded, and melted to make new steel. For more information see ARA Governmental Affairs NVMSRP.

One of the NVMSRP goals was to maximize switch collection nationally.

A $4 million fund was established that was used to reward dismantlers/recyclers in the participating states on a first-come, first-serve basis over a 3-year period for their efforts.

The NVMSRP voluntary incentive fund was depleted as of July 2009. All other aspects of the switch collection program will continue. You are strongly encouraged to continue removing switches and the program will continue to accept these switches at no cost to participants.

End of Life Vehicle Solutions (ELVS) will carry out the program responsibilities for the vehicle manufacturers. Click here for more information.

A recent study shows that releases from auto processing facilities are the fourth largest source of mercury air emissions in the United States. Most of the mercury in automobiles is found in the hood and truck light switches. It is also found in some anti-lock braking and navigational systems.

By removing automotive mercury switches, Wisconsin auto and scrap recyclers can prevent the potential release of almost 300 pounds of mercury to our environment each year and help keep our lakes and rivers free of mercury pollution. This assumes 300,000 cars are recycled in Wisconsin each year and 43% have mercury switches. Only 1 gram of mercury deposited by rain and snow each year can cause a fish consumption advisory on a 20-acre lake. For every automotive mercury switch recycled about 1 gram of mercury is removed from the environment.

The Wisconsin Department of Natural Resources (WDNR) has prepared a guidance document to help auto recyclers manage mercury switch removal. Much of that information is included in the fact sheet below. You can access the link to WDNR's Auto Mercury Switch Removal under Other Relevant Resources.

Regulations

The WDNR has partnered with Wisconsin auto and scrap recyclers to establish a mercury switch recycling program, which is explained below. All auto recyclers are encouraged to participate, as mercury switch removal is not yet a requirement in Wisconsin. However there are other rules for handling mercury switches which you must follow.

If you choose not to participate in the mercury switch recycling program, you have two options:

Recycle the mercury switches as a "Wisconsin-Specific Universal Waste." Hazardous waste regulations for transporting, reporting, accumulation are reduced under this policy.
If not recycling the mercury switches, you must comply with Wisconsin's Hazardous Waste Regulations. The hazardous waste rules cover storage, transportation, recordkeeping, and reporting. Depending on how much hazardous waste you generate, you may need to obtain an EPA hazardous waste number. For a complete review of these requirements see the RCRA Hazardous Waste Plain Language Guide.

If you choose to participate in the mercury switch recycling program, which is encouraged, you should comply with the following instructions (more detailed instructions are contained in the mercury switch recycling guidance document). This voluntary program is available to auto recyclers at no cost. In addition, participants receive a free HG spill kit (while supplies last).

Mercury Switch Storage. Find sturdy semi-clear, plastic containers with a tight-fitting lid. You will need at least two containers if you are handling both metal and glass switches. Store only one pound of mercury per container.

Labeling and Marking. Keep records of the number of switches you collect, date collection started, date transported, origin and destination location. With a permanent marker (legal requirement), label the containers as follows as "Universal Waste: Mercury Switches;" or, Waste: Mercury Switches;" or, "Used Mercury Switches."

Response to Releases. Small spills are those involving less than a dime-sized puddle of mercury metal. A large spill is bigger than a dime-sized puddle and should be handled by hazardous material cleanup professionals. For small spills, keep everyone away from the area, turn off heaters, turn up air conditioners and ventilate the area. If available, use a Mercury Spill Kit. If you do not have a spill kit, refer to the mercury switch guidance document for detailed clean up instructions.

Storing Mercury Wastes. Mercury wastes should be put in a vapor-proof, sturdy unbreakable container. Anything that touched the liquid mercury should be considered contaminated. Only testing by a qualified professional can determine whether clothing and other items are safe to keep.

Crushing Mercury Lamps and Switches. Do not crush the switch. Keep glass switches separate from metal switches in order to prevent breakage. Place some sort of cushioned medium in glass switch storage container help prevent breakage.

Transportation. You may transport mercury switches if you send the switches to approved collection sites, ensure that the containers are safely secured, and comply with all federal and state DOT regulations. Proper handling and recycling of mercury switches exempts you from certain DOT transportation requirements if the switches are in packages of less than one pound.

Collection Sites. Make sure you take your mercury switches to approved collection sites, that you notify the collection facility of any spills inside the container, and give the facility a copy of your mercury switch collection records, or have the containers labeled with that information.

Links to the Regulations. Use the following links to view the regulations pertaining to mercury.

Wisconsin Hazardous Waste Regulations (NR 590.01-690.81)

Wisconsin Universal Waste Regulations (NR 690)

Federal EPA Standards Applicable to Generators of Hazardous Waste

Self-Audit Checklist

When an inspector comes to your facility, there are certain things he or she checks to see if you are in compliance with environmental regulations. It makes good sense for you to perform a "self-audit" and catch and correct problems before they result in penalties. Also, there are some compliance incentives associated with self-audits (see Audit Policy Page).

Use the following list to audit your mercury management program.

Find and properly label containers and keep a record of the number and type of switches collected.
Gather the necessary tools. A mercury spill kit is recommended.
Protect your employees and prevent spills by following proper storage and containment procedures.
Identify which vehicles have mercury switches and other mercury devices.
Remove mercury switches from lighting device and if possibly, place in container.
Transport container to approved mercury switch collection facility in compliance with all federal and state DOT regulations.
If you spill mercury or break a mercury device of any kind, determine if it is a small or large spill. If it is a small spill, use a mercury spill kit or other recommended methods. If it is a large spill, hire a hazardous cleanup professional.

Best Management Practices (BMPs)

Most regulations tell you what you have to do to be in compliance, but they don't explain how to do it. That's where "best management practices" come into play. BMPs are proven methods that help you to get into compliance and stay there.

The following BMPs are recommended for management and disposal of vehicle parts containing mercury:

All employees who handle or manage mercury-added products should be informed of proper handling and emergency procedures for these products and for mercury.
Remove all mercury switches from the vehicle as soon as possible.
Be careful not to break or puncture the mercury container during removal.
If a mercury-containing device breaks, clean it up with a Mercury Spill kit or other recommended methods. If it is a large spill, hire a hazardous cleanup professional.
Store mercury switches in a leak-proof, closed container. Store in a way that will prevent the capsules from breaking.
Label storage containers with "Universal Waste: Mercury Switches;" or, Waste: Mercury Switches;" or, "Used Mercury Switches."
Be able to demonstrate that you have not had the devices stored for more than one year. This can be done by keeping a log, shipping papers, or by labeling storage containers with the accumulation start date.
Recycle mercury switches with an approved mercury device collection facility.

Contacts

For more information, contact Wisconsin's DNR Auto Salvage Sector Resource Specialist at
715-831-3263, or contact the WDNR Regional Office in your area. For northern Wisconsin, call
715-635-2101 or 715-365-8900; West Central Wisconsin, call 715-839-3700; Northeast Wisconsin, call 920-492-5800; Southeast Wisconsin, call 414-263-8500; and, for South Central Wisconsin, call 608-275-3266.
All spills should be immediately reported using Wisconsin's 24-hour toll free hotline at 800-943-0003. If you discover a discharge through analysis of soil or water, use the Hazardous Substance Release Fax Notification Form.

Related ECAR Fact Sheets

Hazardous Wastes

Other Related Resources

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